The Organisation for Economic Cooperation and Development (OECD) released the seventh annual peer review report for Country-by-Country reporting in line with the BEPS Action 13 minimum standard on Monday, 16 September 2024.
This report reflects the outcome of the seventh review which considered all aspects of implementation, containing the review of 138 jurisdictions that provided legislation or information pertaining to the implementation of CbC Reporting.
For each jurisdiction, the review covers the domestic legal and administrative framework, the exchange of information framework and measures in place to ensure the confidentiality and appropriate use of CbC reports.
Under the Action 13 Minimum Standard, jurisdictions have committed to fostering tax transparency by requesting the largest multinational enterprise groups (MNE Groups) to provide the global allocation of their income, taxes, and other indicators of the location of economic activity. This unprecedented information on MNE Groups’ operations across the world has boosted tax authorities’ risk-assessment capabilities.
Key findings
- Domestic legal and administrative framework: Over 115 jurisdictions have a domestic legal framework for CbC reporting in place. In addition, a number of jurisdictions have final legislation approved that is awaiting official publication. In this peer review report, 19 jurisdictions have received a general recommendation to put in place or finalise their domestic legal or administrative framework and 37 jurisdictions received one or more recommendations for improvements to specific areas of their framework.
- Exchange of information framework: Of the jurisdictions included in this review, 93 jurisdictions have multilateral or bilateral competent authority agreements in place.
- Confidentiality: Of the jurisdictions included in this review, 99 have undergone an assessment by the Global Forum on Transparency and Exchange of Information for Tax Purposes (the Global Forum) concerning confidentiality and data safeguards in the context of implementing the AEOI standard, and did not receive any action plan.
- Appropriate use: 84 jurisdictions have provided detailed information, enabling the Inclusive Framework to obtain sufficient assurance that measures are in place to ensure the appropriate use of CbC reports.
The BEPS Action 13 peer review is conducted annually, with the next report scheduled for release in the third quarter of 2025.
